Memorandum of Law and all exhibits attached thereto, Bradley James Edwards, as defendant and counterclaimant in the underlying Florida action, and Freeman Lewis LLP as his New York counsel will move this Court in the Motion Submissions Part Room 130, 60 Centre Street at 9:30 am. on October 29, 2010, or as soon

ION FOR CPLR 3102(E) ORDER ORDER TO PRODUCE TAPE RECORDING Pursuant to CPLR 3102(e) Index No. x An Application having been made by Petitioner Freeman Lewis LLP for the purpose of taking the deposition duces tecum of the Records Custodian of the New York Daily News pursuant to a commission issued by the Cir

foregoing reasons, the Court should order the Daily News to produce the recording. New York, New York November I I, 2010 Respectfully submitted, Freeman Lewis LLP '4/i By: Robert Y. Lewis 228 East 45" Street, 17'h Floor New York, New York 10017 Tel: Fax: Paul G. Cassell (Motion for Pro Hac Vice Admissi

Memorandum of Law and all exhibits attached thereto, Bradley James Edwards, as defendant and counterclaimant in the underlying Florida action, and Freeman Lewis LLP as his New York counsel will move this Court in the Motion Submissions Part Room 130, 60 Centre Street at 9:30 am. on October 29, 2010, or as soon

Memorandum of Law and all exhibits attached thereto, Bradley James Edwards, as defendant and counterclaimant in the underlying Florida action, and Freeman Lewis LLP as his Ncw York counsel will move this Court in the Motion Submissions Part Room 130, 60 Centre Street at 9:30 am. on October 29, 2010, or as soon